← All Phrases

“reasonable cause”

PenaltySection 273BSection 273B7,285 judgments

The decision most relied on for reasonable cause is Ashok Pai v. CIT (292 ITR 11), cited in 812 judgments on BharatTax.

Leading authorities on reasonable cause

Ashok Pai v. CIT
292 ITR 11 · 2007 · Supreme Court
812
citing judgments

“Concealment of particulars of income” and “furnishing inaccurate particulars of income” are two distinct offences under Section 271(1)(c) of the Income Tax Act. A penalty cannot be levied under one limb if the show cause notice or basis for penalty specifies the other, as this constitutes a complete variance in the reasons for assuming jurisdiction.

Collector, Land Acquisition, Anantnag & Anr. v. Mst. Katiji & Ors.
2 SCC 107 · 1987 · Supreme Court
451
citing judgments

Courts must adopt a liberal approach when considering applications for condonation of delay, preferring to decide cases on their merits rather than allowing technicalities of limitation to scuttle justice. This principle applies to ensure the substantive rights of parties are not defeated by minor delays.

Balakrishnan v. M. Krishnamurthy
7 SCC 123 · 1998 · Supreme Court
368
citing judgments

The Supreme Court outlines the principles for condoning delay in filing appeals, stating that a litigant's lapse is not always a bar if the explanation is bona fide and not a dilatory strategy. Courts should show utmost consideration to suitors and prioritize substantial justice unless the delay is deliberately to gain time.

Akhil Bhartiya Prathmik Shikshak Sangh Bhawan Trust v. ADIT
115 TTJ 419 · 2008 · ITAT
292
citing judgments

Penalty under Section 272A(1)(d) for non-compliance with a notice issued under Section 142(1) is not leviable when the assessee demonstrates a reasonable cause for such non-compliance. The decision defines what constitutes 'reasonable cause' in this context.

Sreenivas Charitable Trust v. Dy. CIT
280 ITR 357 · 2006 · High Court
182
citing judgments

The expression "sufficient cause" for condoning delay in filing appeals must receive a liberal and purposive construction. This approach aims to advance substantial justice, which is of paramount importance.

CIT v. K.S.P. Shanmugavel Nadai and Ors.
153 ITR 596 · 1985 · High Court
171
citing judgments

Where a reasonable cause for delay in filing an appeal exists, the period of delay may not be a relevant factor for condonation. The court has condoned even substantial delays, such as nearly 21 years, based on the presence of a reasonable cause.

People Education and Economic Development Society (PEEDS) v. ITO
100 ITD 87 · 2006 · ITAT
121
citing judgments

When substantial justice and procedural technicalities are in conflict, especially in cases involving non-deliberate delay, the cause of substantial justice must be prioritized. The opposing party cannot claim a vested right to benefit from injustice due to such delays.

Commissioner of Income Tax v. Noida Toll Bridge Co. Ltd.
262 ITR 260 · 2003 · High Court
121
citing judgments

Journal entries for accepting or repaying loans and deposits, without any actual cash transaction, do not violate the provisions of Section 269SS or Section 269T of the Income Tax Act. Consequently, such transactions do not attract penalties under Section 271D or Section 271E.

Judgments citing reasonable cause

M/S. Shark Dyeing Mills, Tiruppur vs. ITO, Ward-1(2), Tiruppur

In the result, the appeal filed by the assessee is allowed

ITA 2692/CHNY/2025[2018-19]Status: DisposedITAT Chennai09 Jan 2026AY 2018-19

Bench: Shri George George Kand Ms Padmavathy Sआयकर अपील सं./Ita No.: 2692/Chny/2025 िनधा"रण वष"/Assessment Year: 2018-19 M/S. Shark Dyeing Mills, The Income Tax Officer, No.5A, Suriaprabhagarden, Vs. Ward 1(2), M.P. Nagar Extension, Tiruppur. Tiruppur – 641 607. Pan: Acyfs 7041R (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri S. Sharavanan, F.C.A ""यथ" क" ओर से/Respondent By : Ms. Gouthami Manivasagam, Addl.Cit सुनवाई क" तारीख/Date Of Hearing : 07.01.2026 घोषणा क" तारीख/Date Of Pronouncement : 09.01.2026

For Appellant: Shri S. Sharavanan, F.C.A ""For Respondent: Ms. Gouthami Manivasagam
Section 250Section 271BSection 273BSection 44A

business, etc. It was stated that the above documents were furnished before the AO and the FAA. It was contended that there is ‘reasonable cause’ as mandated u/s.273B of the Act for late filing of audit report, hence, on fact of the instant case, penalty u/s.271B of the Act needs ... said partner is also filed. Taking into account the totality of facts of the instant case, we are of the view that there is reasonable cause as mandated u/s.273B of the Act for not furnishing the audit report within the prescribed time. Further, we also note that the audit report

Sujith Surampudi, Ghatkesar vs. Income Tax Officer, Ward-1, Mancherial

In the result, the appeal filed by the assessee is dismissed

ITA 1630/HYD/2025[2022-23]Status: DisposedITAT Hyderabad07 Jan 2026AY 2022-23

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1630/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2022-23) Shri Sujith Surampudi Vs. Income Tax Officer Ghatkesar Ward 1 Pan:Cwcps7355A Mancherial (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: C.A Swathi Sheela राज" व "ारा/Revenue By:: Smt. Helan Ruby Jesindha, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 23/12/2025 घोषणा की तारीख/Pronouncement: 07/01/2026 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Shri Sujith Surampudi (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”) Dated 15.09.2025 For The A.Y 2022-23. 2. The Assessee Has Raised The Following Grounds Of Appeal: “1. The Order U/S250 Of The Act Dt. 15-09-2025 Passed By The Commissioner Of Income Tax(Appeals), Nfac, Delhi Is Page 1 Of 7

For Appellant: C.A Swathi SheelaFor Respondent: : Smt. Helan Ruby Jesindha, Sr. DR
Section 142(1)Section 144Section 144BSection 144rSection 250Section 272Section 272A(1)(d)

from MSA-P since 2018, for which a medical certificate given by consultant Neurologist dt.14-09-2024 of KIMS Hospital, Hyderabad was filed, which is the reasonable cause for not appearing/ furnishing before the AO in response to notices u/s 142(1) issued ... medical certificate dated 14.09.2024 placed at page no. 32 of the paper book. It was submitted that the non-compliance was due to reasonable cause, and therefore, in terms of section 273B of the Act, no penalty under section 272A(1)(d) of the Act was leviable

Bharat Kumar Bansal, Hyderabad vs. ACIT., Central Circle-2(1), Hyderabad

In the result, all the appeals filed by the assessee are allowed

ITA 1005/HYD/2025[2018-19]Status: DisposedITAT Hyderabad07 Jan 2026AY 2018-19

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1000 To 1006/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2013-14 To 2019-20) Shri Bharat Kumar Bansal Vs. Assistant Commissioner Hyderabad Of Income Tax Pan:Abfpb6416P Central Circle 2(1) Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri A Srinivas, Ca राज" व "ारा/Revenue By:: Shri S. Arun Kumar, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 17/12/2025 घोषणा की तारीख/Pronouncement: 07/01/2026 आदेश/Order Per Bench: These Seven Appeals Are Filed By Shri Bharat Kumar Bansal (“The Assessee”), Feeling Aggrieved By The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-12, Hyderabad (“Ld. Cit(A)”) All Dated 07.03.2025 For The A.Ys. 2013- 14 To 2019-20. Since Common & Identical Issues Are Raised By The Assessee In All These Appeals, For The Sake Of Convenience, These Were Heard Together & Are Being Disposed Of By This Consolidated Order. 2. At The Outset, We Find There Is A Delay Of 06 Days In Filing Of All These Appeals Before This Tribunal. The Assessee Has Page 1 Of 9

For Appellant: Shri A Srinivas, CAFor Respondent: : Shri S. Arun Kumar, Sr. DR
Section 153C

assessee and upon hearing the submissions of the Learned Departmental Representative (“Ld. DR”), we are satisfied that the delay was due to reasonable cause. Accordingly, the delay of 06 days in filing of all these appeals are condoned, and the appeals are admitted for adjudication on merits. 3. Identical grounds